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certified mailpiece was delivered May 25, 2004 to the
Tax Court and signed for by “K. Mitchell.” Our records
also indicated an intermittent scan in Clarksburg New
Jersey on May 13, 2004.
The Clarksburg scan appears to have been in error and
should have been scanned missent. * * * Since our
record show no acceptance scan for the mailpiece, we
can only presume the letter did not enter the mails
prior to May 12, 200[4] if it had been mailed from Zip
Code 07730. * * *
If the item had been mailed on March 30, 2004 according
to information supplied by Mr. Ward, a Postal employee
would have date stamped the receipt. The verification
and date stamp by the Postal employee would also have
been done [on] a customer’s “Firm Sheet” that lists
multiple items. Mr. Ward was unable or did not supply
a dated receipt (or Firm Sheet) that indicated the date
the mailpiece was accepted by a Postal employee to be
deposited into the mails. * * *
Irradiation of Mail
In the June 9, 2004, letter to petitioners’ counsel, the
U.S. Postal Service indicated, among other things, that all mail
addressed to any Government office in Washington, D.C., continues
to be subjected to irradiation to eliminate any anthrax spores.
OPINION
This Court has limited jurisdiction. This Court’s
jurisdiction to redetermine a deficiency depends on the issuance
of a valid notice of deficiency and a timely filed petition.
Rule 13(a), (c); Levitt v. Commissioner, 97 T.C. 437, 441 (1991).
Section 6213(a) provides that a petition for redetermination of a
deficiency determined by respondent is timely filed if it is
filed within 90 days, or 150 days if the notice is mailed to a
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